Government consults on mandatory Changing Places

The government is undergoing a public consultation (part 1) providing the finer details of including Changing Places toilets in the Building Regulations (Document M, Sanitation).

Visit: Changing Places (England) Consultation

You can have your say on issues such as:

  • Types of buildings
  • Trigger values eg cinemas would be based on x number of seats, others triggered by footfall or space.
  • Size and equipment provided
  • Costs to businesses
  • Equality impact assessment of provision.

Full details are contained in the pdf document provided on the consultation page. You can participate by email or online.

Poo at the zoo.

This week is Love your Zoo Week run by BIAZA. The British and Irish Association of Zoos and Aquariums (BIAZA) is the professional body representing the best zoos and aquariums in the UK and Ireland.

Baby elephant
Chester Zoo
 
1.3 million people visit member organisations every year. Only a small percentage are disabled people and their friends/families because few venues provide toilet facilities with 

  1. a hoist and changing bench, 
  2. space for modern wheelchairs or 
  3. one that is fully equipped for able wheelchair users and those with other impairments e.g. Bowel/bladder disorders, autism, mental ill health, epilepsy, obesity, shortened height.

 BIAZA members contribute over £650 million to the national economy.

If the venue doesn’t provide a hoist or height adjustable toilet, this means a lot of people can’t visit. People with poor balance, weak legs or arms may not be able to stand up from an accessible seat. 

People with muscle and nerve disorders, balance or co ordination difficulties or frailty from old age may need this equipment.  They may not necessarily use a wheelchair.  

There are no height adjustable toilets in any zoo, aquariums or wildlife parks in the UK.

If standing up from the loo (or standing by the loo) is impossible, such individuals have to be lifted up / carried in the arms of relatives or find a toilet with a hoist and changing bench. Wheelchair users with weak arms/legs also need hoist facilities.

Hoist, toilet and changing bench
Chester Zoo

There are a number of zoos etc who provide such essential equipment and the space to use it. 

These are:

  • Marwell Zoo (first in UK to equip toilets for all visitors)
  • Bristol Zoo Gardens
  • Blair Drummond Safari Park
  • Tilgate Park
  • Chester Zoo
  • Chessington World of Adventures Resort
  • Tropical Wings Zoo (opening soon)
  • Folly Farm Adventure Park and Zoo
  • Cotswold Wildlife Park
  • Colchester Zoo
  • Yorkshire Wildlife Park (hoist and toilet)
  • Wingham Wildlife Park
  • Pili Palas Nature World
  • Camperdown Wildlife Centre (opening soon)
  • Edinburgh Zoo (hires in a bed and hoist for 1 week per year)
  • Whipsnade

(List excludes bird and wildlife reserves and parks/forests).

Possible future venues:

  • Living Coasts
  • Paignton Zoo
  • Newquay Zoo
  • Twycross Zoo
  • London (only hoist and bench currently – no toilet)

Specifically stating no hoist facilities:

  • Woburn Safari Park

However, there are over 100 venues who do not offer usable toilet facilities – not even for people who don’t use a hoist.

Why do they exclude disabled people?

Train travel and toilets

This week we heard about Anne Wafula Strike in the news – not being able to access the toilet on a long train journey.

The fear of not finding a usable toilet (and risk urinating in your underwear or damaging your bladder and kidneys) is very real. It leaves disabled people choosing the more dignified option – to not make any long journeys by train or car. This leads to major life restrictions around work, health care, leisure and socialising or seeing family.

Until 6 years ago, I had never been on a train. I then had to get into London for specialist hospital services so we started using trains. With my husband, we carefully choose our stations – they have to be 

  1. staffed – to set up ramps to get on and off . (Not all stations have staff present.)
  2. Step free access to the platform. (Some stations have no access to platforms or only access to some platforms in one direction).

It is here we bring into the equation – where will I be able to use the loo along the way.

Where are the usable toilets?

Our main route has been from Tonbridge to London Bridge and Maidstone to Victoria. From the moment I last use the loo at home, the clock starts ticking. I won’t drink anything that day to reduce the need for the loo.

Around an hour has passed and I’m at the station. The toilet door opens straight onto the platform – so my husband who lifts me out of my chair to/from the loo will have to slink out whilst I use it (without exposing me to people on the platform). He will then have to loiter and listen out for me to call him back in. He will get some funny looks – but that’s ‘normal’ for us. It’s not a private affair. 

There is no hoist – so he will have to lift/drag me to the seat. On the plus side it’s clean and has all 3 of the standard set of support rails to cling on to. 

I can’t travel by train to London with my personal assistants as they can only use a hoist to lift me and there are no rail stations with hoist equipped toilets on my route or at my destination. 

On the train

On the train, I need to get assistance into the accessible carriage. This is where the accessible toilet is located. However, on the way home we are sometimes just put in the doorway area because not all trains have accessible carriages or are too full at rush hour. They have no access to the toilets. Staff just want to get people on trains or are they see the accessible coach is a long way away – so they try to board you into the nearest coach with no wheelchair space. 


I can’t use the toilets on trains because my small powerchair won’t fit and there is no space for my husband to lift me. They don’t have hoists. You can see here that if my chair was next to the loo – my husband would not fit in at all. Alas I haven’t mastered levitation.

I often see they are out of order. If I needed the loo I’d have to get staff to cancel the ramp at my destination- and make new arrangements for me to get off at another station –  and back on another train after using the loo. As I’ve just said, stations might be no go areas because they are not step free or staffed.

If it is possible to get off at another station, what if the toilet on that station isn’t usable? Not every toilet has the ‘standard’ space, suppport rails etc. Take this one for example.


We were a few hours on a train for a day out at Ely. My husband had worked out we could use the toilet at the station. He’d even seen a picture on the station’s website. However, we headed straight for the loo only to find the support rail was not standard / too far away from the toilet to hold on to. I would have fallen on the floor. I had heart failure because we were in a new place with no idea where to find a toilet. 


On our way back from Ely to Kings Cross the same problem but thankfully on the left hand side (I need a right hand side rail as it’s the only way I can lean). For someone else this won’t be usable. This toilet is also higher than the recommended standard for safe and manageable transfers from a wheelchair. 

Trains and stations – will they ever be accessible?

I haven’t heard that newly refurbished stations like London Bridge or Cross Rail will have made any improvements to accessing toilets at stations across London. No toilets with larger spaces or hoists being put in. No refurbishing or auditing of current toilets to ensure all access features are present and correctly positioned or offer better privacy.  

I’ve been part of consultations on toilet provision on new trains. The designs did not involve larger spaces or better layouts for wheelchair users. 

There is never a guarantee the toilet will be in working order – but if all stations had improved, usable wheelchair accessible toilets on all platforms, we could at least get off the train at the next staffed station and be confident that I could pee into the loo and not into my knickers. 

Caught short – the myth 

An interesting comment came my way stating that ‘normal’ people caught short should be allowed to use the accessible loo the same as non disabled people who need the loo urgently.

Let’s put this to bed right here. 

We have covered before how part of the criteria of being accessible is ‘availability’ of accessible toilets. I.e not taken up by non disabled people who could go elsewhere.

So what if the non disabled person is caught short? Well the reason is different. One person has, as an adult, improperly and in error been unable to time when they needed to empty their bladder or bowel. With some mental competence, being caught short could have been avoided. They then wouldn’t have had to dive into an accessible toilet?

 Disabled people might have a medical need known as urgency where they may only have a minutes warning before their bladder releases whether they are in the loo or not. Clearly these people with a medical need (or arguably a medical need from an upset stomach or similar) require available facilities of an accessible toilet to preserve health and dignity. 

Simply being caught short because someone has not made time for the toilet in their day is no excuse to use up an accessible toilet. 

What do you think?

Changing Places low usage?

Gill, a fellow toileteer, had a couple of questions – which I felt might be a useful topic to take a look at. Here is the first one:

Changing Places: Changing places room is greatly needed and appreciated by users, but it would appear that in general they get very little use. I believe that this is partly due to signage. The facility might appear on an app but once in the building there may be poor directions. Also once found they might well be locked and someone has to go on a key hunt. Apparently some providers are closing them as they have never been used, and the average usage is once every six months. There’s been a suggestion that they could become a more multi use facility? eg first aid room; baby changing room for a disabled parent. Do you have any thoughts on this?

Changing Places and similar toilets are very valuable. However, imagine you’re a shop or tourist attraction who has invested thousands in providing a large fully accessible toilet with a hoist and bench… only to find it’s rarely used. A waste of money, you say angrily, as you knock it down to make way for valuable retail space. 

Aghhhhh. What went wrong?

We can break down some of the key reasons as to why they are at risk of being underused.

1) The toilet is not signposted within the venue or town.

I’m a CP toilet user and so many times I find there is no signposting. I know from the CP map that the venue has one … but it’s not on any venue map, booklet, and no directions given from public toilet blocks. (O2 Arena, Bluewater Shopping Centre and my local town come personally to mind). 

  • If you don’t tell people where it is then they won’t use it!

Yesterday I looked at the CP map and saw Toddingto Services had one … I went in only to find it was on the northbound side and I was southbound. Whilst it’s on the Google map section of the CP map, the description didn’t indicate which side!

2) The toilet isn’t called a Changing Places. 

Staff might not know that a Changing Places toilet might be labelled, in their venue, as a ‘high dependency unit’ , ‘Space to Change’, ‘Hoist assisted toilet’, ‘Adult Changing Room’ etc. as there is no official standard name.  People who use these toilets might not realise to look/ask for alternative names. (Bluewater/O2 Arena / mobile units come to mind).

In Lincoln castle they have a hoist … but they just call it ‘the accessible toilet’.  No mention of it on their visitor literature!

  • Staff training can help.

3) Location, location, location

These toilets might be a significant investment … so location is critical. Even if a large venue has a CP toilet, if you have to walk for 30 minutes to reach it, you might not use it. Maidstone has one in its council building – great only it’s over 30 minutes fast walk uphill from the museum, theatre, main shopping area etc. It’s quicker for me to drive home!! 

  • Toilets need to be central to the action.

Yesterday I was at Chester Zoo. It’s a huge venue. I was a long way away from the CP toilet (about 600 metres) and it was back in the direction we had come from, so I used a basic loo. Does that count as none use or just my personal choice and need for the loo quicker than we could reach it?  The location is good though and well signposted – in fact I’d say in this instance 2-3 toilets would all be used well. 

  • Sometimes too few CP toilets or wrong locations can risk low overall use.

4) How is use being monitored?

Unless a person has to request one to be opened or someone is constantly watching the entrance (and this is being recorded) then usage monitoring might not be happening.  Use might be ‘guessed’ by  something as simple as ‘the bed paper roll’ still looks full or ‘the toilet roll hadn’t gone down in months’.

These methods have obvious flaws.  Thinking of the many CP toilets I have used, only 1 was visible by staff at a reception desk (who had other work to do rather than to vigilantly act as official toilet monitor). How can venues say with certainty if they are being used or not? 

Do cleaners make notes if it looks ‘used’? 

Most are ‘just toilets’ with no special key  and might be used for clothing changes or something which wouldn’t leave any dent in the toilet roll. I often use my own specialist wipes that are flushable – so you’ll never know I’ve been in.

Could they have other uses?

Thinking about secondary uses, the two obvious choices are noted by Gill. A first aid room or for wheelchair accessible baby changing.

The latter could be problematic in that parents using chairs are likely to need to sit under the changing table area to access their baby and CP benches are not open underneath. A height adjustable baby changing table might be an option that could fit in the full size CP toilet to assist disabled parents.

What about using it as a first aid room? There is nothing in health and safety legislation to suggest that a toilet space can not be a first aid room. However, whether someone would want to be treated in a room with a toilet nearby could be a problematic.  Hygiene and infection control may be an issue and CP benches are often just a shower trolley – not meant for laying on for a prolonged period and not that comfy.  There is also the consideration of what you would do if the room is being used and you needed the toilet or someone needed first aid. How likely this is to occur will depend on many factors. Location of the toilet and size may influence any decision to have a multi use room. For small to medium stores etc, multi use may be worth considering with the addition of a chair and first aid cabinet/wall mounted kit. 

Let a toilet be a toilet 

I see a simple solution. You don’t HAVE to use a bench or hoist to use the facility. Why not just have it as a toilet for use by anyone who would normally need an accessible toilet? Do disabled people in general know they can use it? 

Currently building regulations say that venues need a standard wheelchair accessible toilet  … and CP toilets are additional. 

Well perhaps this should change  – the only difference would be a finger wash basin near the toilet (and this could be fitted in a CP toilet as a moveable / swing out basin perhaps). That way one toilet suitable for all could be provided. Even going as far as enabling parents with children in prams to use the room in smaller venues where low use might be a financial issue? 

Maybe, in small venues, we need to start providing shared facilities that serve more than just disabled hoist/bench users.